Waterkeepers Florida asks the Army Corps to require Twin Pines Minerals to supply all the information missing from its application for a titanium mine near the Okefenokee Swamp, to prepare a full Environmental Impact Statement (EIS), to hold Public Hearings, including in Florida, and “to answer how the Corps has or will determine that the Applicant’s proposed mine would not adversely affect the Okefenokee Swamp, the St. Marys River, the Suwannee River, the Floridan Aquifer, or the State of Florida.”
You can also still comment to the Army Corps.
TPM Equipment closeup Photo: Wayne Morgan for Suwannee Riverkeeper on Southwings flight, pilot Allen Nodorft, 2019-10-05.
See also PDF.
A Resolution that Waterkeepers Florida
Opposes the Application by Twin Pines Minerals for a Titanium Mine near the Okefenokee Swamp,
and asks the U.S. Army Corps of Engineers for an Environmental Impact Statement broad enough to cover Florida issues,
for Public Hearings in Florida,
and to Answer how the Corps has determined or will determine that this mine would not affect Florida
WHEREAS, the Okefenokee Swamp, partly in Florida; is a national and international treasure, for its wetland ecology, and for boating, fishing, and birding, and for hunting nearby; and
WHEREAS, the Okefenokee National Wildlife Refuge (NWR) provides more economic benefit to Florida than any other NWR (see U.S. Fish and Wildlife Service, Banking On Nature 2017: The Economic Contributions of National Wildlife Refuge Recreational Visitation to Local Communities https://www.fws.gov/economics/divisionpublications/bankingOnNature/BoN2017/bon2017.asp); and
WHEREAS, the Okefenokee Swamp is the headwaters of the Suwannee River and of the St. Marys River, both of which are partly in Florida; and
WHEREAS, any change in the water level of the Swamp would affect the entire Okefenokee Swamp and the Suwannee River and the St. Marys River; and
WHEREAS, the Applicant’s proposed mine in Charlton County, Georgia, would sit above the Floridan Aquifer, from which most of Florida drinks; and
WHEREAS, the miners have applied to the Georgia Environmental Protection Division (GA-EPD) to withdraw 4.32 million gallons per day of water, more than four times as much as Folkston, the county seat of Charlton County (see http://wwals.net/?p=50227); and
WHEREAS, the Floridan Aquifer is already under stress with declining water levels from withdrawals in south Georgia and north Florida, including from existing mines; and
WHEREAS, the Applicant company, Twin Pines Minerals, is already under a Consent Order for multiple violations at four Chemours mine sites in north Florida (see http://wwals.net/pictures/2019-02-07–lfco-chemours); and
WHEREAS, infractions similar to those of the Florida Consent Order at the mine site in Georgia could adversely affect the Okefenokee Swamp, the St. Marys River, and the Suwannee River; and
WHEREAS, the only two Waterkeepers that straddle the GA-FL state line, Suwannee Riverkeeper and St. Marys Riverkeeper, have filed comments with the U.S. Army Corps of Engineers asking for a full Environmental Impact Statement and Public Hearings (see http://wwals.net/?p=50140 and http://wwals.net/pictures/2019-09-12–st-marys-rk-usace-tpm/); and
WHEREAS, most of the Riverkeepers of Georgia filed their own comments, or comments supporting the comments filed with the Corps by Suwannee Riverkeeper; and
WHEREAS, all the above-mentioned Waterkeepers or Riverkeepers are Members of the Waterkeeper Alliance, and Waterkeeper Alliance supports the comments filed with the Corps by Suwannee Riverkeeper; and
WHEREAS, the comments filed with the Corps by Southern Environmental Law Center (SELC) include important legal and other points relevant to Florida (see http://wwals.net/pictures/2019-09-12–selc-usace-tpm/); and
WHEREAS, all the above-mentioned comments, as well as ones filed with the Corps by the U.S. Environmental Protection Agency and the Georgia Environmental Protection Division, cite information lacking from the Application, especially about hydrology and hydrogeology (see http://wwals.net/?p=50199); and
WHEREAS, the Corps received at least 20,338 comments before its nominal comment deadline, far more than for most applications (see http://wwals.net/?p=50158)
NOW, THEREFORE, BE IT RESOLVED that Waterkeepers Florida is opposed to the mining Application SAS-2018-00554 as filed, and Waterkeepers Florida is filing a request with the U.S. Army Corps of Engineers:
- to require the Applicant to supply all the missing information identified by Suwannee Riverkeeper, St. Marys Riverkeeper, and SELC; and
- to prepare a full Environmental Impact Statement (EIS) broad enough to cover all the concerns and answer all the questions raised by the above-named three organizations, especially those concerns and questions relevant to Florida; and
- to hold Public Hearings, including in Florida; and
- to answer how the Corps has or will determine that the Applicant’s proposed mine would not adversely affect the Okefenokee Swamp, the St. Marys River, the Suwannee River, the Floridan Aquifer, or the State of Florida.
PASSED AND ADOPTED BY WATERKEEPERS FLORIDA, this 23rd day of October 2019.
Much more about that titanium mine application: wwals.net/issues/titanium-mining/
The comment deadline was May 28, 2020, according to SAS-2018-00554 Twin Pines Minerals, Published April 13, 2020, Expiration date: 5/28/2020.
“The Savannah District will hold a virtual Public Meeting for the Twin Pines project on May 13, 2020 from 2:00 PM to 5:00 PM EDT. The meeting will consist of a formal presentation followed by a question and answer session. The meeting will be recorded and published to the Savannah District public website. To allow time for the public to submit questions and RSVP to the public meeting, as well as comment on any information presented at the meeting, additional public comments will be accepted and the original public notice will remain open until May 28, 2020, 15 days after the virtual public meeting.”
However, you can write to your elected officials. And the Corps apparently actually continues to read comments after the deadline, right up until they make a decision. While you are at home because of the novel Coronavirus (COVID-19), you have a great opportunity to write a comment, and to You can also post your comments on social media, as op-eds, etc.
You can ask the Corps and other elected and appointed officials to deny the application, or to require an Environmental Impact Statement (EIS) to consider wider areas the mine may affect, especially the entire Okefenokee Swamp, the Suwannee and St Marys Rivers, and the rest of Trail Ridge in Georgia. You can ask for the EIS to include other mines relevant to this one, especially the four Chemours titanium strip mines in north Florida for which TPM, along with Chemours, is under a Florida Consent Order for a range of violations. You may want to ask for inclusion of the existing phosphate mine in Hamilton County, Florida, next to the Suwannee River, as well as the one proposed in Union and Bradford Counties, Florida, next to the New and Santa Fe Rivers, tributaries of the Suwannee. All those mines affect the Floridan Aquifer, which is the main source of water for drinking, agriculture, and industry for everyone in south Georgia and north Florida.
To comment, or to request a public hearing, you can write to
Commander, U.S. Army Corps of Engineers, Savannah District,
Attention: Ms. Holly Ross, 1104 North Westover Boulevard, Suite 9, Albany, Georgia, 31707,
or by email to CESAS-SpecialProjects@usace.army.mil or email@example.com.
In your comments please refer to:
Applicant: Twin Pines Minerals, LLC, Application Number: SAS-2018-00554.
For the requested state permit regarding Section 401 of the Clean Water Act, you can send a comment or request for public hearing to
Stephen Wiedl, Wetlands Unit, firstname.lastname@example.org
Georgia Department of Natural Resources, Environmental Protection Division, Water Protection Branch, 7 Martin Luther King, Jr. Drive, Atlanta, Georgia 30334.
For the Georgia Coastal Management Program certification, you can send a comment to
Federal Consistency Coordinator, Ecological Services Section, Coastal Resources Division,
Georgia Department of Natural Resources, One Conservation Way, Brunswick, Georgia 31523-9600
The public announcement says: “The applicant may also require assent from the State of Georgia, which may be in the form of a license, easement, lease, permit, or other appropriate instrument.”
You can write to your Georgia state representative or senator
or governor or lieutenant governor and ask them to refuse any such instrument.
To find your legislator you can type in your ZIP code here: http://openstates.org/find_your_legislator/
You can also write to your U.S. Representative or Senator and ask them to urge the Corps to reject this mine or at least require an EIS, like Rep. Al Lawson (FL-05) already did.
You can also write to the Georgia DNR board, asking them to refuse any such instrument.
Georgia Board of Natural Resources
2 Martin Luther King Jr. Drive, SE, Suite 1252, Atlanta, GA 30334
You can write to the U.S. Environmental Protection Agency (EPA) asking them to ask the state of Florida to comment.
To: Mary S. Walker, Regional Administrator, email@example.com
Jeaneanne Gettle, Director, Water Division, firstname.lastname@example.org
Blake Ashbee, Chief of Staff, email@example.com,
Carol Kemker, Director, Enforcement & Compliance Assurance Division, firstname.lastname@example.org
Region 4, U.S. Environmental Protection Agency (EPA)
Cc: Gregory J. Strong, Director, Northeast Division, Greg.Strong@dep.state.fl.us
Noah Valenstein, Director, Noah.Valenstein@dep.state.fl.us
Florida Department of Environmental Protection (FDEP)
Col. Daniel Hibner, Commander, U.S. Army Corps of Engineers,Savannah District
Attention: Ms. Holly Ross, email@example.com,
1104 North Westover Boulevard, Suite 9, Albany, Georgia 31707
Stephen Wiedl, Wetlands Unit, firstname.lastname@example.org
Georgia Department of Natural Resources, Environmental Protection Division,
Water Protection Branch, 7 Martin Luther King, Jr. Drive, Atlanta, GA 30334
Re: Applicant: Twin Pines Minerals, LLC, Application Number: SAS-2018-00554
Dear Administrator Walker and Director Gettle,
Here is the pithy request sent by Waterkeepers Florida:
We request EPA to determine, according to 33 CFR § 325.2(b), whether the mining activities of the applicant may affect the quality of the waters of the state of Florida and to notify the state of Florida, the district engineer, and the applicant that Florida therefore “has 60 days from receipt of EPA's notice to determine if the proposed discharge will affect the quality of its waters so as to violate any water quality requirement in such state, to notify EPA and the district engineer in writing of its objection to permit issuance, and to request a public hearing.”
To submit a letter to the editor of the Charlton County Herald,
you can email email@example.com.
Or write to your local newspaper.
You can also contact radio, TV, and of course post on social media.
-jsq, John S. Quarterman, Suwannee RIVERKEEPER®
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